1. NSF Tribal College Workshop Award Monitoring & Business Assistance November 14, 2008

2. 2 Ask Early, Ask Often! NameTitleContact Charlie ZeiglerSpecial Assistant, Cost Analysis & Audit Resolution Division of Institution & Award Support (DIAS); Office of Budget, Finance & Award Management (BFA) czeigler@nsf.gov (703) 292-4578

3. 3 NSF Award Portfolio Active award dollars - $19.7 billion Active awards – 34,370 Awardee Institutions – 2,200 81% of NSF awards less than $500,000 Tribal Colleges 39 awards $81,893,262 Average Tribal College award size $2,099,827 at 22 organizations

4. 4 BSF Risk Assessment Award Factors – Amount, Type of award instruments, Sub-awards, Participant Support, Equipment, Institutional Factors – Awardee Type, NSF Cognizant, Experience Previous Monitoring results – OIG Audits, A- 133, Site Visits, Desk Reviews NSF Admin & Program – FCTR, FPR, Special Payment, Annual Call to Program

5. 5 Post Award Monitoring Program Business System Reviews – Large Facilities Award Monitoring and Business Assistance Site Visits – CAAR & DGA Award Monitoring Desk Reviews – CARRB contract with Booz Allen Hamilton Transaction Testing – DFM contract with McBride Lock & Associates Baseline Monitoring – DGA DACS NSF OIG – Audit & Investigations

6. 6 Baseline Monitoring DGA, DACS, DFM – general NSF business Systems, automated checks and system edits, generating awards, continuing increments No Cost Extensions, Change in PI, Cost Sharing, Financial Reporting FCTR-FFR, Award Terms & Conditions, Approvals Program – Annual Reports, Site Visits, Mid- Term Review – future funding years 4-5, PI meetings

7. 7 Transaction Testing - DFM Contract with McBride Lock & Associates for Improper Payment Act – Government wide requirement Based on Risk Assessment – Statistical Sample by category FCTR reconciliation between costs reported and Project Cost Accounting record Select Sample transaction – allowable cost

8. 8 Award Monitoring Desk Reviews Contract with Booz Allen Hamilton High and Medium Risk Organizations General Management Survey – written policies and Procedures, Organization Chart, Duties and Key Personnel, Expenditure Approvals Accounting & Financial – Allowable Costs, A- 133 audit, Project Cost Accounting, Time & Effort Reporting, Cost Policy Statement (direct or indirect), FCTR Reconciliation

9. 9 AMBAP – Site Visits High Risk and Program Recommended Core Review Modules – General Management, Accounting & Financial System, FCTR reconciliation Targeted Review Modules – Time & Effort, Fringe Benefits, Travel, Consultants, Cost Sharing, Participant Support, Indirect Costs, Procurement, Subrecipient Monitoring, Property & Equipment, Program Income, Final Project Reporting

10. 10 Business System Reviews Large Facility Office – Research Platforms, Construction MREFC, FFRDC, all high risk awards Modules or Systems– Award Management, General Management, Planning & Budget, Financial Management, Financial Reporting, Procurement, Property & Equipment, Human Resources.

11. 11 Audits OMB Circular A-133 (Old A-128) requires Annual Independent Audit if expenditures of Federal Funds > $500,000 / year Schedule of Federal Financial Assistance, Compliance, Internal Control, Transaction Testing NSF OIG – Audit and Investigations

12. 12 AMBAP Site Visits Pre-Site Visit – 4 weeks – Notify awardee and Coordinate time, Request Documentation, Internal – PO & Award Review, Analysis, Plan Site Visit – 3-4 days - Entrance Conference, Field Work & Interviews, Exit Conference Post Site Visit – 90 days - draft report, Letter to awardee, Awardee Responds Close-out – 10 days - Determination on awardee response, Corrective action and Follow-up - if required

13. 13 General Management Organizational Structure Internal Controls Written policies and Procedures and how well they are followed Management Staff & Duties Safeguards and crosschecks – segregation of duties

14. 14 Accounting & Financial Sytems Management and accounting controls related to charges on NSF award Financial Accounting System Project Cost Accounting Books of Account – General Ledger, Project Ledger, Chart of Accounts, Journals - Receipts, Disbursements, Purchases Unallowable cost accounting

15. 15 FCTR Reconciliation Billing system and requests for funds from NSF = Cost shown in award project accounts Established procedures for preparing requests Can reconcile draw downs to expenditures for the project Minimize time to expend if receives advances

16. 16 Time & Effort Reporting Policies and Procedures for completing Can bill based on budget or estimates, but After the Fact Verification of Actual Effort Signed by Employee or Supervisor First Hand Knowledge of employee activities (suitable means of verification) Accounts for all activities (percentage) Generally, prepared at least semi-annually (faculty)

17. 17 Travel Written policies and procedures Documentation of costs Per diem rates or actual In-Travel Status (local meals?) US Flag Air-carriers Premium Airfare

18. 18 Participant Support Costs Funds budgeted for P/S – requires NSF PO approval to re-budget Account for through sub account code Exclude from IDC allocation base Documentation attendance eligibility workshops Not Employees – Stipends, Allowances, other payments

19. 19 Procurement Written policies and procedures (purchasing manual) Segregation of Duties, Approval Levels, Authorities Sole source Justification, Excluded Parties, COI Cost and Price Analysis Required flow down provisions

20. 20 Subrecipient Monitoring Prime awardee responsible for sub- awardee (privity of contract) Preaward Review – risk assessment Subcontract document (clauses and flow down) Monitoring – Technical, Financial A-133 reports Special award Conditions

21. 21 Property & Equipment More than $5,000 and one year useful life Scientific not general purpose Exclude from IDC calculation Records and Inventory Title vesting

22. 22 Questions? Charlie Zeigler Cost Analysis & Audit Resolution (703) 282-4578 czeigler@nsf.gov